Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Valuation - related parties - technical knowhow fee is for design, drawing and technical information provided to appellant by overseas supplier for setting up of "Instant Coffee" plant which is purely a post-importation activity - value cannot be enhanced - AT
Valuation - related parties - technical knowhow fee is for design, drawing and technical information provided to appellant by overseas supplier for setting up of "Instant Coffee" plant which is purely a post-importation activity - value cannot be enhanced - AT
Note: It is a system-generated summary and is for quick reference only.